This Advisory Circular relates specifically to Civil Aviation Rules Part 147. Published by Civil Aviation Authority PO Box 3555 Wellington 6140

Transcription

1 Advisory Circular AC Part 147 Maintenance Training Organisations - Certification Revision December 2015 General Civil Aviation Authority Advisory Circulars contain information about standards, practices, and procedures that the Director has found to be an Acceptable Means of Compliance (AMC) with the associated rule. An AMC is not intended to be the only means of compliance with a rule, and consideration will be given to other methods of compliance that may be presented to the Director. When new standards, practices, or procedures are found to be acceptable they will be added to the appropriate Advisory Circular. An Advisory Circular may also include guidance material (GM) to facilitate compliance with the rule requirements. Guidance material must not be regarded as an acceptable means of compliance. Purpose This Advisory Circular (AC) provides methods acceptable to the Director for showing compliance with the certification requirements of Part 147 for aviation maintenance training organisations. This material is intended for applicants for, and holders of, aviation maintenance training organisation certificates. Related Rules This Advisory Circular relates specifically to Civil Aviation Rules Part 147. Change Notice Published by Civil Aviation Authority PO Box 3555 Wellington 6140 Authorised by Manager Rules Development

2 Table of Contents General... 1 Purpose... 1 Related Rules... 1 Change Notice... 1 Introduction... 3 Related Civil Aviation Rules (CAR), Advisory Circulars (AC) and CAA Policies... 3 Other References... 3 Abbreviations... 3 Forms... 3 Subpart A General... 4 Applicability... 4 Subpart B Maintenance Training Organisation Certificate... 4 General Scope of this Subpart Application for Maintenance Training Organisation Certificate... 4 Organisational requirements General Facility Requirements Basic training facilities Aircraft type and aircraft task facilities requirements Personnel Requirements Documentation Safety Management Systems including Internal Quality Assurance Records Training courses, practical assessments, and knowledge examinations Organisation s exposition Changes to Certificate Holder s Organisation Exposition to be made available Ratings specified on certificate Duration of Certificate Grant or Renewal of Certificate Subpart C Restricted Maintenance Training Organisation Certificate General Scope of this Subpart Application for restricted maintenance training organisation certificate Organisational requirements Personnel, general facility, and documentation requirements Records Certificate Ratings specified on certificate Duration of certificate Grant of certificate December

3 Introduction Civil Aviation Rule Part 147, which came into force on 1 February 2016, prescribes the requirements for the certification and operation of an organisation conducting aviation maintenance training. This advisory circular provides guidance for applicants requiring certification. Related Civil Aviation Rules (CAR), Advisory Circulars (AC) and CAA Policies CAR Part 43 General Maintenance Rules CAR Part 66 Aircraft Maintenance Personnel Licensing CAR Part Safety Management CAR Pat 145 Aircraft Maintenance Organisations-Certification AC 00-3 Internal Quality Assurance AC Safety Management Systems AC 66-1 Aircraft Maintenance Engineer Licence - General CAA Certification Policy - Organisations CAA Surveillance Policy CAA Handbook: Fit and Proper Person Process Other References International Civil Aviation Organisation (ICAO); Annex 1 Personnel Licensing Doc 7192 Training Manual Part D-1 Aircraft Maintenance Airlines for America Inc. (A4A - formerly Air Transport Association of America (ATA)) Specification 104 Abbreviations The following abbreviations are not contained in CAR Part 1 but are included for the purposes of this advisory circular: AC means Advisory Circular AMEL means Aircraft Maintenance Engineers Licence CAA means Civil Aviation Authority of New Zealand Director means Director of Civil Aviation LAME means Licensed Aircraft Maintenance Engineer MTOC means a Maintenance Training Organisation Certificate Forms 147/01 Issue, renewal, or amendment of a MTOC 147/02 Exposition Amendment Summary Sheet for a MTOC 16 December

4 24147/03 Part 147 Rule Compliance Matrix 24FPP 24FPPDEC Fit and Proper Person Questionnaire Fit and Proper Person Declaration Subpart A General Applicability Rule prescribes rules governing the certification and operation of organisations where the Civil Aviation Rules require an organisation to be certificated under this Part in order to conduct aviation engineering training. Part 147 does not itself determine which training courses are to be conducted under this Part. Part 147 provides a means for the Director to ensure that certain training courses are conducted by either (1) Organisations holding a MTOC for the purpose of conducting ongoing training courses and assessments; and subject to surveillance against their exposition by the Director; or (2) Organisations holding Restricted MTOC for the purpose of conducting one-off or stand alone training courses; and subject to inspection by the Director against the appropriate requirements of this Part. Subpart B Maintenance Training Organisation Certificate General Scope of this Subpart Rule applies to organisations that conduct maintenance training courses, knowledge examinations or practical assessments on a regular basis as required by rule 147.3(a). Rule 147.3(d) provides that an organisation can be a sole trader or a partnership Application for Maintenance Training Organisation Certificate An applicant for an MTOC will need to consider certain factors relating to training and competency of its personnel. The application form CAA 24147/01 must be completed in full and must identify the full extent of the intended training to be conducted under the certificate. This information will be used in determining the scope of the operation and the assessment and preparation of the Schedule of Conditions. The application is to be supported by providing the appropriate senior persons applications, including Fit and Proper Persons forms, the Part 147 matrix as appropriate, and the exposition as required by rule The certification process takes time to complete; therefore it is strongly recommended that an application is submitted at least 90 days before the intended operation. An application for an MTOC less than 90 days from the date of the intended operation may risk not having the application process completed in time. Please refer to Certification Policy Organisations, the CAA strongly recommends that all applicants read this policy prior to making an application. 16 December

5 Operators should plan their certification programme in advance and early consultation with the CAA will ensure all issues are dealt with well before the planned start-up date. The time involved for certification is dependent on the quality and completeness of the application and exposition. Note: The 90 day period starts from the time a complete application is received by the CAA. Organisational requirements General Facility Requirements Rule requires applicants for grant of a MTOC to provide facilities and resources appropriate to the training courses listed in the applicant s exposition. This AC does not list these in detail because that would be too restrictive, especially with the range of activities that could be conducted under a Part 147 certificate. However the following guidelines are a minimum: facilities to be kept in a clean and orderly condition consistent with the required professional character of the organisation; and each space used for instructional and examination/assessment purposes to be adequately equipped, heated, lighted, and ventilated; and accommodation environment to be maintained such that students are able to concentrate on their studies or examination as appropriate, without undue distraction or discomfort; and each space used by instructors for course preparation purposes and meeting with individual students is to be adequately equipped, heated, lighted, and ventilated; and training aids and equipment, including any audio-visuals, mock-ups, charts, synthetic trainers, aircraft or aircraft components listed in the training course outline, to be accurate and appropriate to the course for which they are used; and students enrolled on a training course are to have appropriate training material made available, covering the complete syllabuses to the appropriate standard. This material is to be supplemented by general reading material; and The storage facility referenced in rule 147.7(b) must provide adequate security for examination papers etc Basic training facilities For each basic training course: That the classroom used for theory training is separate from the workshop used for practical training; and That the workshop used for practical training has the appropriate facilities and equipment to provide the training; In the case of a basic training course, basic training workshops and/or maintenance facilities separate from training, classrooms to be provided for practical instruction appropriate to the planned training course. If, however, the organisation is unable to provide such facilities, arrangements may be made with another organisation to provide such workshops and/or maintenance facilities, in which case a written agreement shall be made with such organisation specifying the conditions of access and use. The CAA shall require access to any such contracted organisation and the written agreement must specify this access. 16 December

6 Aircraft type and aircraft task facilities requirements For each aircraft specific type rating or specific part of aircraft training the certificate holder must provide appropriate samples of components relevant to the type training being conducted. This requirement may be met by suitable synthetic training devices Personnel Requirements Rule (a)(1) requires each applicant for the grant of a MTOC to engage, employ or contract a senior person identified as the Chief Executive. S/he will have the overall authority within the organisation, including financial authority, to ensure that the necessary resources are available to provide the training courses conducted under this Part. The Chief Executive is required to ensure that the organisation s activities are carried out in accordance with the procedures contained in their exposition. Rule (a)(2) requires the applicant to engage, employ or contract one or more senior persons accountable to the Chief Executive. They should be suitably qualified for the positions held. Irrespective of the titles used or the number of senior persons nominated, all areas of responsibility applicable to the organisation s activities are to be addressed. The areas of responsibility referred to in (a)(2) include Safety Management Systems including Internal Quality Assurance: Responsibility for the organisation s SMS procedures; Responsibility for monitoring of the organisation s compliance with Part 147 and with its exposition, and Responsibility for ensuring the adequacy of the organisation s exposition and associated procedures in meeting the requirements specified in Part 147 and in reflecting the organisation s activities, and Responsibility for ensuring the implementation of actions to correct deficiencies in the organisation s documentation and procedures that are detected during internal quality assurance reviews, audits, or inspections of the organisation s activities, and Responsibility for ensuring that conditions attached to the certificate or to any exemption are complied with. The areas of responsibility referred to in (a)(3) include - Training management and delivery and responsibility for the organisation s training; Instructors Course material Training records Rule (c) requires the applicant to establish a procedure for initially assessing and for maintaining the competence of those personnel conducting the training courses, practical assessments and knowledge examinations listed in the applicant s exposition. The competence assessments are expected to ensure that staff have the necessary levels of training, qualification, and experience; and staff have an adequate knowledge of the organisation s procedures relevant to their role in that organisation; and 16 December

7 on-the-job competency checks are carried out at regular intervals with appropriate continuation training to maintain competency levels; and continuation training includes instruction on changes in regulatory requirements and standards; and changes to the organisation s procedures and exposition. To help in the assessment of a person s competence referred to in rule (c), job descriptions should be formulated for all positions within the certificate holder s organisation. The job descriptions for all personnel should define their responsibilities, authority, and their interrelationships. This is particularly important for personnel who need organisational freedom and authority and should include written documentation of any person s authorisations. Rule (a)(3) requires each applicant for grant of a MTOC to engage, employ or contract sufficient personnel to plan, conduct, and supervise the training courses listed in the applicant s exposition. Where a certificate holder engages a third party to meet any requirement, the certificate holder remains responsible for that requirement. This includes compliance with the procedures, including personnel competence, as detailed in the certificate holder s exposition. Note: All senior persons are to be fit and proper persons and are, at the time of application, to provide the Director with the details required on form CAA 24FPP or 24FPPDEC as appropriate Documentation Rule (a) requires each applicant for the grant of an MTOC to establish procedures to ensure that it has all relevant publications, technical standards etc to satisfactorily provide the training courses listed on its Schedule of Conditions, Rule (b) requires each applicant for the grant of an MTOC to establish procedures to control the documents required by rule (a) Safety Management Systems including Internal Quality Assurance Rule requires each applicant for the grant of a standard MTOC to establish a Safety Management System that meets the requirement of Part 100. Refer to AC Records Rules (a) requires each applicant for the grant of an MTOC to establish procedures to identify, collect, index, store, and maintain the records that are necessary for the training courses listed in the applicant s exposition. The records required by rule (a) may be kept in any format and shall be controlled by a responsible senior person. Access to the record system should be controlled to ensure that the integrity of the records is maintained. The Director may require access to any of the records for certification or surveillance or other purposes. Computer systems may be used to control and record details of training courses, knowledge examinations etc. Records may be microfilmed, photocopied, carbon copied, magnetically copied, or scanned and saved to optical media (i.e. CD ROM / DVD for any purpose), but the original record either electronic or otherwise, must be retained for the required period (of 5 years). The records described under this paragraph should be stored in a manner that ensures protection from damage, alteration and theft. Computer backup servers, discs, tapes etc. should be stored in a different location from that containing the working server, discs, tapes etc., in an environment that 16 December

8 ensures they remain in good condition. Procedures for electronic record and document keeping should consider the following: (a) avoidance of data loss in the event of power interruptions; (b) software control, including amendments and prevention of corruption; (c) prevention of unauthorised access; (d) audit trail facilities; (e) archiving of data in a similar manner to hardcopies, and for a similar period; (f) backup of critical information, preferably once a day, with storage for that backup information; (g) data verification, on entry and retrieval; (h) publication provision; (i) staff training; (j) amendment and protection of stored data; (k) a problem report register including the problem details and solutions. These requirements should be documented in an exposition and subject to safety management or QMS controls. The records must be retained for a minimum period of five years from date of completion of the training. The question of privacy legislation has been raised with regard to student records. CAA advice would be to obtain students permission for the use and disclosure of the personal information to the CAA and other agencies for the various purposes described above on the grounds that having these records allows CAA to accept the course. It will also be in the students interests if the proof of their training is retained for as long as possible. Note: FAA AC contains more information on electronic record keeping systems Training courses, practical assessments, and knowledge examinations Rule requires procedures to ensure that courses meet the applicable syllabus requirements of the Civil Aviation Rules and are conducted without any compromise of the integrity of the syllabi. Rule requires the applicant to ensure that each person conducting training that is required by the Civil Aviation Rules to be conducted by an organisation certificated under this Part, has a combination of qualifications and experience greater than the level of qualification being taught or assessed. Part 147 covers many areas of training and assessment, and because of all the permutations of qualifications and experience available (professional, technical and educational), it is neither possible nor desirable to completely list these Organisation s exposition Rule (a) requires an applicant for the grant of an MTOC to provide the Director with an exposition. The purpose of the exposition is to set forth the procedures, means and methods of the organisation. The exposition will only be accepted if it meets the requirements of Part 147. The exposition is the means by which the certificate holder defines the operation. It shows both the employees and the Director how the certificate holder will conduct their day-to-day business. The exposition is intended to be a tool to assist management in the operation of the business. The administration/management section of the exposition should normally be contained within one document. It should commence with the corporate commitment by the Chief Executive. The remaining parts of the exposition may be produced as any number of separate chapters or manuals. 16 December

9 The following paragraphs address the individual requirements of the exposition: Under the rules system, each certificate holder has the responsibility to ensure that their operation is planned, organised, carried out, maintained, developed and documented according to applicable regulatory requirements, standards, and operating specifications. As part of their safety system of management, each certificate holder should establish goals and objectives for their operation including safety standards equal to or above the level prescribed by the Director. The signed statement by the Chief Executive required by rule (a)(1) is accepted by the Director as a corporate commitment by the certificate holder. The statement should clearly address the goals and objectives of the certificate holder in respect of the safety requirements prescribed by Part 147. The statement may also contain the certificate holder s goals and objectives in respect of their commercial activities. The exposition should be a tool of management to present the certificate holder s operation to their staff, customers and to the Director. The certificate holder needs to show the lines of responsibility and communication between the Chief Executive and the work front. The chart should show the relationship between the central body of the organisation and any satellite locations where staff are permanently based. The applicant is to list the training courses to be covered by the certificate, and the locations at which they will be conducted. The course outline and curriculum is more than just the syllabuses and might include the following information - A description of each room used for ground training, including its size and the maximum number of students that may be instructed in the room at one time: The qualifications and experience for each instructor position: The prerequisites required for enrolment in the course: A description of each lesson, including its objectives and standards and the measurable unit of student accomplishment or learning to be derived from the lesson or course: The time scale of the course: A description of the tests and checks used to measure a student s accomplishment at appropriate stages during the training: The student attendance required by the organisation for satisfactory completion of the course and how any reasonable shortfall can be made up. These procedures are required as part of the exposition as they provide the working documents for controlling the certificate holder s activities that can directly affect the training courses and assessments conducted. The information should include the types of training courses and assessments conducted. The procedures may include references to other internal instructions and are to include the quality assurance procedures that are an essential element of the quality management system. The headings are generally selfexplanatory and are to be addressed by all applicants to the extent that they apply to the particular scope of intended activity. More detailed information will be found under the paragraphs that call for the procedure. 16 December

10 These procedures show how the certificate holder plans to control, amend and distribute the exposition. The procedures should be similar to those required in rule for controlling, amending and distributing the certificate holder s documentation. The acceptance of the applicant s exposition by the Director is the final step in approval for the issue of an MTOC Changes to Certificate Holder s Organisation Rule requires each holder of a MTOC to ensure that their exposition is amended so as to remain a current description of the holder s organisation. The exposition is intended to be a living document to reflect the organisation s activities and its means to carry out those activities. Therefore, as the organisation s activities, means, methods and facilities change, the exposition is to be changed accordingly. The Director is to be kept informed of these changes and therefore a copy of each amendment to the exposition is to be forwarded to the Director. Any changes to the certificate holder s procedures or standards that may affect the functions of the organisation need to be properly documented with background information and reasons for the change. Such documentation should be retained for possible audit trail purposes. Rule (b) specifies the changes to the exposition that require the prior approval of the Director. This includes the senior personnel where the fit and proper person criteria are to be met, and changes that require a change to the certificate. The Director may also prescribe conditions that may be necessary because of a change in these items. The conditions may be transitional to allow the certificate holder to continue to operate while arrangements are made to incorporate permanent changes. This could also apply to course duration changes or adding a new variant to the aircraft type rating course Exposition to be made available The exposition may be electronic and applicable parts must be available to staff to enable them to carry out their duties. Certificate Ratings specified on certificate The MTOC specifies the training courses that the holder is authorised to conduct under the classifications training courses. The following is the list of training course rating disciplines available: (i) (ii) (iii) (iv) E1 for basic training courses; E2 for aircraft type or task training courses; E3 for examinations conducted on behalf of the Director; E4 for other courses relevant to maintenance training. Possible examples: E1 basic engineering, gas turbine theory, aerodynamics E2 Bell 212, Airbus A320, Pratt and Whitney Canada PT6, Turbomeca Arriel E4 Human Factors 16 December

11 Schedule of Conditions The Schedule of Conditions accompanies the MTOC and provides the detail of the training courses authorised by the certificate. The Director may amend the Schedule of Conditions at any time as the operator changes and develops their training options. The Schedule of Conditions is automatically generated by the CAA database at the time of producing the certificate and is based on the data taken from the CAA 24147/01 application form. Therefore it is important that the applicant ensures that the scope of the intended training courses is clearly identified on this form and it is covered in the exposition. Where a holder of an MTOC has been granted specific exemptions against the rules, these will also be listed on the holder s operations specifications Duration of Certificate Rule allows a standard MTOC to be granted or renewed for a period of up to five years. This complies with the CAA Certification Policy - Organisations that no Certificate of Approval for an organisation should be non-terminating. However, to enable the organisation to demonstrate compliance with their exposition and Part 147 the initial issue of a certificate will generally be for a shorter period typically two years.. In the second year prior to the expiry of the certificate the CAA will carry out the renewal process commonly called recertification or re-entry. In terms of the Rules, this process is known as the re-issue of the Certificate. The organisation must apply for the re-issue Grant or Renewal of Certificate Rules (a)(1) and (2) require an application for the grant or renewal of a MTOC, which will be made on form CAA 24147/01. Rule (a)(2) (applying rule 147.5(a)(2)) requires application for renewal or reissue to be submitted to the Director before the application renewal date specified on the certificate. Notwithstanding this requirement, it is the responsibility of the applicant to ensure application is made in sufficient time to avoid certification expiring. Where a MTOC has been in force for the full five year period, the application will be subject to an entry-level inspection. The scope of such an inspection will depend on a review of the conduct of the certificate holder and on the safety monitoring programme findings over the preceding period of validity. Subpart C Restricted Maintenance Training Organisation Certificate General Scope of this Subpart Rule (a) applies to organisations that conduct maintenance training courses, knowledge examinations or practical assessments on an irregular basis as described in rule (b)(1) and (b)(2) Rule (c) provides that an organisation can be a sole trader or a partnership. 16 December

12 Application for restricted maintenance training organisation certificate An applicant for a restricted MTOC will need to consider certain factors relating to training and competency of its personnel. The application form CAA 24147/01 must be completed in full and must identify the full extent of the intended training to be conducted under the certificate. This information will be used in determining the scope of the operation and the assessment and preparation of the Schedule of Conditions. The application is to be supported by providing the appropriate training persons applications, including Fit and Proper Persons forms, the Part 147 matrices as appropriate, and the specific training course syllabus as required by rule The certification process takes time to complete; therefore it is strongly recommended that an application is submitted at least 90 days before the intended operation. An operator who applies for a restricted MTOC less than 90 days from the date of the intended operation may risk not having the application process completed in time. Please refer to the CAA Policy; Certification Policy Organisations. Operators should plan their certification programme in advance and early consultation with the CAA will ensure all issues are dealt with well before the planned start-up date. The time involved for certification is dependent on the quality and completeness of the application. Note: The 90 day period starts from the time a complete application is received by CAA. Organisational requirements Personnel, general facility, and documentation requirements Rule requires each applicant for the grant of a restricted MTOC to engage, employ or contract sufficient personnel to plan, conduct, and supervise the training course listed in the application. Where a certificate holder engages a third party to meet any requirement, the certificate holder remains responsible for that requirement. Rule requires the applicant to ensure the personnel who are conducting the training course have a combination of qualifications and experience greater than the level of qualification being taught. Part 147 covers many areas of training, and because of all the permutations of qualifications and experience available (professional, technical and educational), it is neither possible nor desirable to provide a definitive list. Rule requires the applicant to have facilities and resources appropriate to the training course listed in their application. Rule requires the applicant to have documented procedures for conducting the training course listed in their application Records Rule (a) requires each applicant for the grant of an restricted MTOC to establish procedures to identify, collect, index, store, and maintain the records that are necessary for the training courses listed in the applicant s exposition. The records required by rule (a) may be kept in any format and should be controlled by a responsible senior person. Access to the record system should be controlled to ensure that the integrity of the records is maintained. The Director may require access to any of the records for 16 December

13 certification or safety audit or other purposes. Computer based systems may be used in place of paper for documents provided sufficient controls are established to maintain the integrity of the information held, and to provide a level of traceability equivalent to that required for paper documents. The records shall be retained for a minimum period of five years from date of completion of the training. The question of privacy legislation has been raised with regard to student records. Civil Aviation Authority advice would be to obtain students permission for the use and disclosure of the personal information to the CAA and other agencies for the various purposes described above on the grounds that having these records allows Civil Aviation Authority to accept the course. It will also be in the students interests if the proof of their training is retained as long as possible. Certificate Ratings specified on certificate The Restricted MTOC specifies the training courses that the holder is authorised to conduct under the classifications training courses : (1) E1 for basic training courses (2) E2 for aircraft type or task training courses (3) E3 for examinations conducted on behalf of the Director (4) E4 for other courses relevant to maintenance training. Schedule of Conditions The Schedule of Conditions accompanies the Restricted MTOC and provides the detail of the training courses authorised by the certificate. The Director may amend the Schedule of Conditions at any time as the operator changes and develops their training options. The Schedule of Conditions is automatically generated by the CAA database at the time of producing the certificate and is based on the data taken from the CAA 24147/01 application form. It is therefore important that the applicant ensures that the scope of the intended training courses is clearly identified on this form and it is covered in the exposition Duration of certificate Rule allows a restricted MTOC to be granted for the period required to conduct a single training course, and it will be dated accordingly. A Restricted MTOC may not be renewed or extended, however new certificates may be issued Grant of certificate In accordance with section 9 of the Civil Aviation Act 1990, the Director may grant a certificate that has been applied for under rule December